Operators who attended the Railroad Commission of Texas’ session In the Field: Ensuring Compliance for Inactive Wells at this year’s Regulatory Conference walked away with something rare: a clear picture of what inspectors actually evaluate in the field. RRC staff walked through the criteria in detail and flagged the violations they see most often, all of which are easy to avoid.
Consider two common examples. An operator certifies that all surface equipment has been removed from a site without confirming it in person. If the inspector arrives and finds old equipment still there, that certification becomes a serious violation. Or an operator leaves electrical service connected to an inactive well. That earns a violation too, regardless of intent.
The Standard, by Years Inactive
Texas ties inactive well obligations to how long a well has been out of service. At one year of inactivity, electrical service must be physically terminated. Between five and ten years inactive, all piping, tanks, vessels, and equipment must be emptied or purged. At ten years, all surface equipment and junk must be removed. Beyond ten years, only the wellhead and an identification sign should remain. Everything else must come off the site, aside from equipment owned by the electric utility.
Potential Enforcement Consequences
The consequences for getting this wrong are significant. The RRC can impose administrative penalties of up to $25,000 per violation. A false certification is also a criminal offense, punishable by up to five years in prison.
Non-compliance carries operational consequences too. The RRC can cancel an operator’s Certificate of Compliance and bar the operator from renewing or securing approval for other wells.
When in Doubt, Ask
If there is any doubt about whether a well meets these standards, contact RRC directly. Its staff are available to answer questions before an inspection, not just after.
Beatty & Wozniak’s regulatory and midstream teams are available to assist clients in navigating these requirements and respond to RRC inquiries or enforcement actions. For more information, please contact Ahuva Battams, Theresa Sauer, Tyler Weidlich, Miguel Suazo, or Raj Lahoti.